If I have an FFL07 and the required SOT for manufacturing, can I do the following:

Contract work to a CNC Machine Shop that does not have the licensing as long as I am there the entire time for production, and no firearms are stored on their premises.
The work in question is to produce a receiver.

ParallaxTactical.com

08-06-2010, 1:29 AM

I believe the answer is no, the shop must have their own license.

This is what calvary arms got into trouble for I believe.

NSR500

08-06-2010, 1:54 AM

I thought it was about an interstate sales issue.

JeffM

08-06-2010, 2:49 AM

Manufacturing must be done on the premise (address) listed on the FFL.

NSR500

08-06-2010, 2:53 AM

Damn the man!!!

Hmm... Maybe I'll have to have 80% manufactured and finish them myself then.

ke6guj

08-06-2010, 12:16 PM

There is no SOT needed, unless you are planning on making NFA firearms, such as MGs, SBS, SBR, AOWs, or suppressors.

I'm pretty sure that you can do what you want to do, stay on site while the recievers are machined and then the machine shop would not need thier own FFL.

The Cav Arms example is not a good one since they were having the molding shop mold both halves and then CavArms was welding the two halves together. ATF later ruled that the two unwelded halves were considered a firearm, and since CavArms wasn't on site, that it was unlicensed manufacture. Plus ATF decided that CavArms was doing other stuff wrong with regards to the manufacturing.

I would suggest contacting ATF to confirm exactly what the current regulations state.

Valkyriearms

08-06-2010, 12:27 PM

I believe you would have to get a variance from the ATF if you're going to have another shop manufacture the receivers for you. In which case you both would need to have an 07FFL.

ke6guj

08-06-2010, 12:35 PM

obviously if you contract that other shop manufacture the receivers for you when you are not there in person to overlook the manufacturing process, that the shop woulld need its own 07FFL, and would need a variance for that 07FFL to mark the receivers with your 07FFL info.

The difference is that in the past, ATF has allowed an 07FFL to subcontract work out to another shop to do the work and that the other shop did not need to be a licensed manufacturer if the 07FFL overlooked the entire manufacturing process and did not leave any firearms at that outside vendor. Whether that is still a viable option, I dunno, and would suggest that you contact ATF to confirm.

NSR500

08-06-2010, 10:53 PM

Thanks guys!

franklinarmory

08-09-2010, 7:31 AM

I asked ATF the same question. They were OK with it, so long as I supervised the whole process. When I contacted the state, the DOJ said that was a no-go.

ke6guj

08-09-2010, 12:52 PM

hmm, I wonder what legal reason DOJ gave for the no-go.

NSR500

08-10-2010, 12:35 AM

I asked ATF the same question. They were OK with it, so long as I supervised the whole process. When I contacted the state, the DOJ said that was a no-go.

That's why it is so damn hard to make a business. Fed, State, and Local all want to screw with you 6 ways from Sunday.

Table Rock Arms

08-11-2010, 10:50 AM

I believe you would have to get a variance from the ATF if you're going to have another shop manufacture the receivers for you. In which case you both would need to have an 07FFL.

This is the answer. I had my ATF interview for my 07 FFL last Friday. They guy from ATF made it very clear that this is how it works. A lot of Manufactures have receivers made for them buy someone else, and you must get a variance from ATF to do it. Not hard to do, but the person doing the work must also be an 07 FFL.